Facebook, Inc. (Petitioner)
`v.
`Windy City Innovations, LLC (Patent Owner)
`
`•
`•
`•
`•
`
`IPR2016-01156; Patent 8,458,245
`IPR2016-01157; Patent 8,407,356
`IPR2016-01158; Patent 8,473,552
`IPR2016-01159; Patent 8,694,657
`
`October 19, 2017
`Before Karl D. Easthom, David C. McKone, and J. John Lee, Administrative Patent Judges
`
`1
`
`Facebook Ex. 1200
`
`
`v.
`Windy City Innovations, LLC (Patent Owner)
`
`•
`•
`•
`•
`
`IPR2016-01156; Patent 8,458,245
`IPR2016-01157; Patent 8,407,356
`IPR2016-01158; Patent 8,473,552
`IPR2016-01159; Patent 8,694,657
`
`October 19, 2017
`Before Karl D. Easthom, David C. McKone, and J. John Lee, Administrative Patent Judges
`
`1
`
`Facebook Ex. 1200
`
`
`
`Summary of IPR Proceedings and Instituted Grounds
`
`Proceeding
`IPR2016-01156 and
`IPR2017-00709
`(’245 Patent)
`
`Instituted Grounds
`Claims
`1–5, 7, 9–14, 19, and 22–25 Roseman, Rissanen, Vetter, Pike, and Westaway
`
`6, 8, 15, 17, and 18
`
`Roseman, Rissanen, Vetter, Pike, Westaway, and
`Lichty
`
`IPR2016-01157
`(’356 Patent)
`
`1–5, 8, 9, 12, 14–16, 19–24,
`27, 28, 31, 33–35, and 37
`
`Roseman, Rissanen, and Vetter
`
`6, 7, 17, 26, and 36
`
`Roseman, Rissanen, Vetter, and Pike
`
`18 and 25
`
`1–59 and 64
`
`Roseman, Rissanen, Vetter, and Gosling
`
`Roseman, Rissanen, Vetter, Pike, and Lichty
`
`189, 203, 209, 215, 221, 334,
`342, 348, 465, 477, 482, 487
`492, 580, 584, and 592
`
`Roseman, Rissanen, Vetter, Pike, and Lichty
`
`IPR2016-01158
`(’552 Patent)
`
`IPR2016-01159 and
`IPR2017-00659
`(’657 Patent)
`
`2
`
`
`
`Claim 1 of the ’245 Patent
`
`U.S. Patent 8,458,245
`Ex. 1001
`
`–Challenged independent claims 7 and 19 are similarly structured
`
`3
`
`
`
`Claim 1 of the ’356 Patent
`
`U.S. Patent 8,407,356
`Ex. 1001
`
`–Challenged independent claims 19 and 37 are similarly structured
`
`4
`
`
`
`Claim 1 of the ’552 Patent
`
`U.S. Patent 8,473,552
`Ex. 1001
`
`–Challenged independent claims 2, 10,18, 50 and 54, 58, 59 and 64 are similarly structured
`
`5
`
`
`
`Claims 189 and 465 of the ’657 Patent
`
`U.S. Patent 8,694,657
`Ex. 1001
`
`6
`
`
`
`Claim Construction
`
`Term
`
`“token”
`“censored” / “censorship” / “censor”
`
`“channel”
`
`“database”
`
`Board’s Construction
`“piece of information associated with user identity” (DI (-1156) at 7)
`“controlled with respect to what is said in a group” (DI (-1156) at 9) /
`“control of what is said in a group” (DI (-1157) at 10) /
`“control what is said in a group” (DI (-1158) at 13)
`“group of participator computers in active communication” (DI (-1157) at 9)
`
`“a collection of logically related data” (DI (-1158) at 10)
`
`“pointer” / “pointer-triggered
`message on demand”
`
`“a link or reference to a file, data, or service” (DI (-1158) at 14) /
`“a message, where the content of the message is specified by a pointer and
`found on demand of the operator of the participator software”
`(DI (-1158) at 15)
`No apparent dispute between the parties for “token,” “channel,”
`“pointer,” “pointer-triggered message on demand”
`
`7
`
`
`
`Claim Construction of “database”
`
`Petitioner’s
`Proposed Construction
`
`Patent Owner’s
`Proposed Construction
`
`“a collection of logically
`related data”
`
`“a collection of logically
`related data which is
`stored with persistence
`and associated with tools
`for interacting with the
`data such as a DBMS”
`
`Panel’s Construction for
`Institution
`
`“a collection of logically
`related data”
`
`–Pet. Reply (-1158) at 3
`
`–PO Response (-1158) at 12
`
`–DI (-1158) at 10
`
`8
`
`
`
`Claim Construction of “database”
`
`• No intrinsic support for PO’s proposed construction requiring persistent storage
`and DBMS
`
`–’245 Patent, 8:6-18
`
`• Self-serving statements in prosecution of related applications carry no weight
`–Pet. Reply (-1158) at 4–6
`
`–Moleculon Research Corp. v. CBS, Inc., 793 F.2d 1261 (Fed. Cir. 1986), disapproved on another point,
`Egyptian Goddess, Inc. v. Swisa, Inc., 543 F.3d 665 (Fed. Cir. 2008) (en banc)
`
`9
`
`
`
`Claim Construction of “database”
`
`• No extrinsic support for Patent Owner’s proposal
`- DBMS unnecessary for storage and retrieval of data
`
`–Ex. 1021 at ¶ 13–14
`
`–Ex. 1017 at 1–2; Ex. 1021 at ¶ 12
`
`10
`
`
`
`Claim Construction of “censor”
`
`Petitioner’s
`Proposed Construction
`
`“control of what is said
`in a group”
`
`Patent Owner’s
`Proposed Construction
`
`“examine in order to
`suppress or delete
`anything considered
`objectionable”
`
`Panel’s Construction for
`Institution
`
`“control of what is said
`in a group”
`
`–Pet. Reply (-1158) at 3
`
`–PO Response (-1158) at 13
`
`–DI (-1158) at 13
`
`11
`
`
`
`Claim Construction of “censor”
`
`Petitioner and Panel construction supported by express intrinsic language:
`
`U.S. Patent 8,458,245
`8:36-44,
`Ex. 1001
`
`12
`
`
`
`|PR2016-O1156; Patent 8,458,245
`IPR2016-01156; Patent 8,458,245
`
`13
`
`
`
`Grounds in IPR2016-01156
`
`1. Claims 1–5, 7, 9–14, 19, and 22–25 Obvious in View of Roseman, Rissanen, Vetter,
`Pike, and Westaway
`2. Claims 6, 8, 15, 17, and 18 Obvious in View of Roseman, Rissanen, Vetter, Pike,
`Westaway, and Lichty
`
`Roseman,
`Ex. 1003
`
`Rissanen,
`Ex. 1004
`
`Vetter,
`Ex. 1005
`
`Pike,
`Ex. 1006
`
`Westaway,
`Ex. 1007
`
`Lichty,
`Ex. 1008
`
`14
`
`
`
`IPR2016-01156 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Pointer-triggered private message
`4.
`Internally determines whether or not the second of the
`participator computers can present the communication
`5. Censorship
`6. Login username and password
`
`–Pet. Reply & Supp. Reply
`
`15
`
`
`
`“internet”: Roseman
`
`Roseman,
`Ex. 1003
`
`– Ex. 1003 (-1156), 1:19–23
`
`–Ex. 1003 (-1156), 1:33–41
`
`–Petition at 9, 17–18
`
`16
`
`
`
`“internet”: Vetter
`
`Vetter,
`Ex. 1005
`
`–Ex. 1005 (-1156) at 003;
`Petition at 18–19
`
`17
`
`
`
`“internet”: Vetter
`
`Vetter,
`Ex. 1005
`
`–Ex. 1005 (-1156) at 004;
`Petition at 19
`
`18
`
`
`
`Motivation to Combine
`
`Reuters News Article,
`Apr. 1997,
`Ex. 1019
`
`–Pet. Reply at 8 n.3
`
`19
`
`
`
`Motivation to Combine
`
`Bob Metcalfe on What’s
`Wrong With the Internet,
`Page 14,
`Ex. 1018
`
`–Ex. 1021 ¶ 22
`
`20
`
`
`
`Motivation to Combine
`
`Bob Metcalfe on What’s
`Wrong With the Internet,
`Page 9,
`Ex. 1018
`
`–Ex. 1021 ¶ 22
`
`21
`
`
`
`“tokens”: Roseman
`
`Roseman,
`Ex. 1003
`
`–Ex. 1003 (-1156), 9:32–48
`
`–Ex. 1003 (-1156), 6:60–61
`
`–Ex. 1003 (-1156), 10:61–64
`
`–Petition at 21–22, 26–27
`
`22
`
`
`
`“database”: Roseman
`
`–Ex. 1003 (-1156), 9:61–63
`
`–Ex. 1003 (-1156), 10:61–64
`
`–Ex. 1003 (-1156), 9:49–53
`
`–Ex. 1003 (-1156), 2:21–27
`
`Roseman,
`Ex. 1003
`
`–Petition at 27
`
`23
`
`
`
`“database”: Rissanen
`
`Rissanen,
`Ex. 1004
`
`–Ex. 1004 (-1156), 1:21–28
`
`–Ex. 1004 (-1156), 2:22–29
`
`–Petition at 28–29
`
`24
`
`
`
`Motivation to Combine
`
`Q. And similarly by early 1996 a person of ordinary skill in the art
`could have used a database to store information associated
`with users’ identity; right?
`A. You mean beyond the password, like a user name or other
`access information? Yes.
`**
`*
`*
`*
`Q. When you reviewed the Roseman patent, was there anything in
`it that would prevent the storage of keys in a database?
`A. I don't believe there was any statement or functionality to that
`effect that would prevent.
`
`–Ex. 1016 at 43:25–44:7, 54:22–55:3; Pet. Reply at 13
`
`25
`
`Deposition of
`Jaime G. Carbonell,
`June 26, 2017,
`Ex. 1016
`
`
`
`Motivation to Combine
`
`“The test for obviousness is not whether the features of a secondary
`reference may be bodily incorporated into the structure of the primary
`reference.”
`
`–Allied Erecting and Dismantling Co., Inc. v. Genesis Attachments, LLC, 825 F.3d 1373, 1381
`(Fed. Cir. 2016) (quoting In re Keller, 642 F.2d 413, 425 (C.C.P.A. 1981))
`
`“It is well-established that a determination of obviousness based on
`teachings from multiple references does not require an actual, physical
`substitution of elements.”
`
`–In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012)
`
`26
`
`
`
`“other programs”: Roseman
`
`Two theories provided:
`1. Conference rooms maintained on host computer; or
`2. Participator computer programs
`
`–Pet. Reply at 17–19
`
`Roseman,
`Ex. 1003
`
`–Ex. 1003 (-1156), 12:16–19
`
`–Ex. 1003 (-1156), 10:8–11
`
`–Ex. 1003 (-1156), 12:1–10
`
`–Petition at 30–31; Pet. Reply at 17–19
`
`27
`
`
`
`“pointer-triggered private message”: Roseman
`
`–Ex. 1003 (-1156), 14:53–57
`
`–Ex. 1003 (-1156), 9:26–31
`
`Roseman,
`Ex. 1003
`
`– Ex. 1003 (-1156), 8:1–13
`
`–Ex. 1003 (-1156), Fig. 12
`
`–Petition at 34–35, 39–40; Pet. Reply at 21–22
`
`28
`
`
`
`“pointer-triggered private message”: Pike
`
`Pike,
`Ex. 1006
`
`–Ex. 1006 (-1156) at 058
`
`–Petition at 36
`
`29
`
`
`
`Motivation to Combine
`
`“A person of ordinary skill in the art would have
`understood that, once a system is communicating over the
`Internet, the URL is a preferred means to identify
`resources on the Internet….
`
`[I]t was well-known to send messages containing Internet
`URLs. Pike describes a technique for allowing a user to
`send URLs for interesting Internet resources in email
`messages to other people. This capability was well-known
`because, in part, it was one of the original design goals of
`the URL….
`
`By April 1996, therefore, a person of ordinary skill in the
`art would have found nothing non-obvious about adapting
`the document-on-the-table feature of Roseman to send a
`message containing an Internet URL to meeting
`participants.”
`
`–Ex. 1002 at ¶ 82–84
`
`30
`
`Declaration of Tal
`Lavian, Ph.D.
`Ex. 1002
`
`
`
`“internally determines…obtaining an agent with an ability
`to present the communication”: Roseman
`
`Roseman discloses presenting the communication
`
`Roseman,
`Ex. 1003
`
`–Ex. 1003 (-1156), 8:1–13
`
`–Petition at 42–43
`
`31
`
`
`
`“internally determines…obtaining an agent with an ability
`to present the communication”: Pike
`
`–Ex. 1006 (-1156) at 075
`
`Pike,
`Ex. 1006
`
`–Ex. 1006 (-1156) at 075–076
`
`–Ex. 1006 (-1156) at 116
`
`–Petition at 43–44
`
`32
`
`
`
`“internally determines…obtaining an agent with an ability
`to present the communication”: Westaway
`
`–Ex. 1007 (-1156) at 1:10–16
`
`Westaway,
`Ex. 1007
`
`–Ex. 1007 (-1156) at 1:18–29
`
`–Petition at 45–47
`
`33
`
`
`
`“internally determines…obtaining an agent with an ability to present
`the communication”: Westaway
`
`–Ex. 1007 (-1156) at 4:59–66
`
`Westaway,
`Ex. 1007
`
`–Ex. 1007 (-1156) at 5:11–26
`
`–Petition at 45–57
`
`34
`
`
`
`Motivation to Combine
`
`Roseman: No limit on file type
`
`–Ex. 1003 (-1156), 8:1–13
`
`“[A] person of ordinary skill in the art would have understood that a
`meeting participant could place a document on the table that other
`participants could not view using currently-installed software
`applications, making the teachings of Pike and Westaway
`particularly useful.”
`
`–Ex. 1002 ¶ 103
`
`–Petition at 48–49
`
`35
`
`
`
`“censored”: Roseman
`
`–Ex. 1003 (-1156), 11:38–50
`
`Roseman,
`Ex. 1003
`
`–Ex. 1003 (-1156), 12:29–45
`
`–Petition at 57–58
`
`36
`
`
`
`“censored”: Lichty
`
`Lichty,
`Ex. 1008
`
`–Ex. 1008 (-1156) at 087–089
`
`–Petition at 58–60
`
`37
`
`
`
`“login name and password”
`
`’245 Patent, Independent Claims 7 and 19
`
`’245 Patent
`
`38
`
`
`
`“login name and password”: Roseman
`
`Roseman,
`Ex. 1003
`
`–Ex. 1003 (-1156), 6:64–7:3
`
`–Petition at 52
`
`39
`
`
`
`“login name and password”: Roseman
`
`–Ex. 1003 (-1156), 10:61–64
`
`–Ex. 1003 (-1156), 10:66–11:1
`
`–Ex. 1003 (-1156), 11:11–13
`
`Roseman,
`Ex. 1003
`
`“[U]nder a broadest reasonable interpretation, we do not find that
`“associated” as recited in “second information associated with the first
`information from a second application program” is limited to a pre-
`existing relationship. We determine that “associated” is construed as
`“connected or related”….
`–Apple Inc. v. Arrendi S.A.R.L., Case IPR2014-00207, Final Written Decision,
`Paper 32, at 7-8 (P.T.A.B. June 9, 2015)
`
`–Petition (IPR2017-00709) at 28–29; Pet. Supp. Reply at 3–4
`
`40
`
`
`
`“login name and password”: Rissanen
`
`Rissanen,
`Ex. 1004
`
`–Ex. 1004 (-1156), 1:29–41
`
`–Ex. 1004 (-1156), 2:22–29
`
`–Petition at 52
`
`41
`
`
`
`42
`
`IPR2016-01156 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Pointer-triggered private message
`4.
`Internally determines whether or not the second of the
`participator computers can present the communication
`5. Censorship
`6. Login username and password
`
`
`
`
`
`|PR2016-O1157; Patent 8,407,356
`IPR2016-01157; Patent 8,407,356
`
`43
`
`
`
`Grounds in IPR2016-01157
`
`1. Claims 1–5, 8, 9, 12, 14–16, 19–24, 27, 28, 31, 33–35, and 37 Obvious in View of
`Roseman, Rissanen, and Vetter
`2. Claims 6, 7, 17, 26, and 36 Obvious in View of Roseman, Rissanen, Vetter, and Pike
`3. Claims 18 and 25 Obvious in View of Roseman, Rissanen, Vetter, and Gosling
`
`Roseman,
`Ex. 1003
`
`Rissanen,
`Ex. 1004
`
`Vetter,
`Ex. 1005
`
`Pike,
`Ex. 1006
`
`Gosling,
`Ex. 1007
`
`44
`
`
`
`IPR2016-01157 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Virtual connection / multiplexing
`
`
`
`–Pet. Reply
`
`45
`
`
`
`’356 Patent, Claim 1[e]
`
`’356 Patent,
`Claim 1[e]
`
`46
`
`
`
`“multiplexing”: Roseman
`
`Host receives different types of messages from participator computer, and
`routes them to the appropriate recipient via network connection:
`
`Roseman,
`Ex. 1003
`
`–Petition at 45-46; Pet. Reply at 22–23
`
`47
`
`
`
`“virtual connection”: Roseman
`
`Roseman,
`Ex. 1003
`
`–Petition at 48–49; Pet. Reply at 20–21
`
`48
`
`
`
`“virtual connection”
`
`Even a graphical representation of a document, message, conference
`room, or other piece of information on a participator computer qualifies as
`an “object”:
`
`Q. So earlier you referred to channel objects and private messaging
`objects. I just want to understand what your understanding of an
`object is.
`A. The way it’s referred to in the patent it means items of information.
`It can be a figure, it can be a video clip, it can be audio.
`Q. So an object is an item of information, as you understand it?
`A.
`In the context of the patent, that seems to be the—objects in
`computer science usually refer to data objects except in object-
`oriented programming it can be pieces of computer software. I
`think object in this context is the types of data objects that were
`mentioned throughout the specification.
`
`–Ex. 1016 at 111:20–112:14; Pet. Reply at 21
`
`49
`
`Deposition of
`Jaime G. Carbonell,
`June 26, 2017,
`Ex. 1016
`
`
`
`50
`
`IPR2016-01157 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Virtual connection / multiplexing
`
`
`
`
`
`|PR2016-O1158; Patent 8,473,552
`IPR2016-01158; Patent 8,473,552
`
`51
`
`
`
`Grounds in IPR2016-01158
`
`1. Claims 1-59 and 64 Obvious in view of Roseman, Rissanen, Vetter, Pike, and Lichty
`
`Roseman,
`Ex. 1003
`
`Rissanen,
`Ex. 1004
`
`Vetter,
`Ex. 1005
`
`Pike,
`Ex. 1006
`
`Lichty,
`Ex. 1007
`
`52
`
`
`
`53
`
`IPR2016-01158 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Censorship
`4. Pointer-triggered message
`5. Two client software alternatives
`
`
`
`
`
`“two client software alternatives”: Roseman
`
`–Ex. 1003, 12:1–10
`
`“It was well-known that providing a software product for multiple computing
`platforms (e.g. Windows, Macintosh, etc.) was desirable because it makes
`the software more commercially attractive and increases the number of
`users who can use it.”
`
`–Ex. 1002 at ¶ 73
`
`–Petition at 28; Pet. Reply at 22–23
`
`54
`
`
`
`IPR2016-01158 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Censorship
`4. Pointer-triggered message
`5. Two client software alternatives
`
`
`
`–Pet. Reply
`
`55
`
`
`
`|PR2016-O1159; Patent 8,694,657
`IPR2016-01159; Patent 8,694,657
`
`56
`
`
`
`Grounds in IPR2016-01159
`
`1. Claims 189, 203, 209, 215, 221, 334, 342, 348, 465, 477, 482, 487, 492, 580, 584, and
`592 Obvious in View of Roseman, Rissanen, Vetter, Pike, and Lichty
`
`Roseman,
`Ex. 1003
`
`Rissanen,
`Ex. 1004
`
`Vetter,
`Ex. 1005
`
`Pike,
`Ex. 1006
`
`Lichty,
`Ex. 1007
`
`57
`
`
`
`58
`
`IPR2016-01159 Disputes
`
`Patent Owner disputes:
`1.
`Internet
`2. The database serving as a repository of tokens for other
`programs to access
`3. Pointer-triggered message
`4. Two client software alternatives
`5. Censored
`
`
`
`
`
`Patent Owner’s Motion to Exclude
`Should Be Denied
`
`59
`
`
`
`Proper Scope of Replies
`
`§ 42.23 Oppositions and replies.
`(b) All arguments for the relief requested in a
`motion must be made in the motion.
`A reply may only respond to arguments raised in
`the corresponding opposition, patent owner
`preliminary response, or patent owner response.
`
`60
`
`
`
`Petitioner’s Reply Evidence in IPR2016-01156 Is Proper
`
`Patent Owner’s Objection to Ex. 1021 Original / Responsive Disclosure
`
`At ¶ 54, lines 1–17
`
`At ¶ 74, lines 1–6
`(specific to -1157)
`
`• Originally disclosed in Ex. 1002 at ¶ 74
`• Responsive to Carbonell Ex. 2005 at ¶ 52
`
`–Paper 41 at 4–5
`
`• Originally disclosed in Ex. 1002 (-1157) at ¶ 105
`• Responsive to Carbonell Ex. 2005 (-1157) at ¶¶ 67-69
`–Paper 41 at 6–7
`
`61
`
`
`
`Petitioner’s Reply Evidence in IPR2016-01157 Is Proper
`
`Patent Owner’s Objection to Ex. 1021 Original / Responsive Disclosure
`
`At ¶ 54, lines 1–17
`
`At ¶ 74, lines 1–6
`
`At ¶ 75, lines 4–10
`
`• Originally disclosed in Ex. 1002 at ¶ 74
`• Responsive to Carbonell Ex. 2005 at ¶ 52
`
`–Paper 39 at 4–5
`
`• Originally disclosed in Ex. 1002 at ¶ 105
`• Responsive to Carbonell Ex. 2005 at ¶¶ 67–69
`–Paper 39 at 6–7
`
`• Originally disclosed in Ex. 1002 at ¶¶ 75, 100
`• Responsive to Carbonell Ex. 2005 at ¶¶ 67–69
`–Paper 39 at 7–8
`
`62
`
`
`
`Petitioner’s Reply Evidence in IPR2016-01158 Is Proper
`
`Patent Owner’s Objection to Ex. 1021 Original / Responsive Disclosure
`
`At ¶ 54, lines 1–17
`
`At ¶ 74, lines 1–6
`(specific to -1157)
`
`At ¶ 75, lines 4–10
`(specific to -1157)
`
`• Originally disclosed in Ex. 1002 at ¶ 74
`• Responsive to Carbonell Ex. 2005 at ¶ 52
`
`–Paper 39 at 4–5
`
`• Originally disclosed in Ex. 1002 (-1157) at ¶ 105
`• Responsive to Carbonell Ex. 2005 (-1157) at ¶¶ 67-69
`–Paper 39 at 6–7
`
`• Originally disclosed in Ex. 1002 (-1157) at ¶¶ 75, 100
`• Responsive to Carbonell Ex. 2005 (-1157) at ¶¶ 67-69
`–Paper 39 at 7–8
`
`63
`
`
`
`Petitioner’s Reply Evidence in IPR2016-01159 Is Proper
`
`Patent Owner’s Objection to Ex. 1021 Original / Responsive Disclosure
`
`At ¶ 54, lines 1–17
`
`At ¶ 74, lines 1–6
`(specific to -1157)
`
`At ¶ 75, lines 4–10
`(specific to -1157)
`
`• Originally disclosed in Ex. 1002 at ¶ 74
`• Responsive to Carbonell Ex. 2005 at ¶ 52
`
`–Paper 39 at 4–5
`
`• Originally disclosed in Ex. 1002 (-1157) at ¶ 105
`• Responsive to Carbonell Ex. 2005 (-1157) at ¶¶ 67-69
`–Paper 39 at 6–7
`
`• Originally disclosed in Ex. 1002 (-1157) at ¶¶ 75, 100
`• Responsive to Carbonell Ex. 2005 (-1157) at ¶¶ 67-69
`–Paper 39 at 7–8
`
`64
`
`
`
` Thank You
`Thank You
`
`65
`
`
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